TemplateEU

EU Digital Services Act (DSA) Transparency Report Template

A reporting-ready template aligned to DSA Articles 15, 24 and 42.

Built for clarity, metric definitions, reproducibility, and the current Commission reporting-template rules.

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Author

Sorena AI

Published

Feb 21, 2026

Updated

Feb 21, 2026

Sections

Structured answer sets in this page tree.

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Cited legal and guidance references.

Publication metadata

Sorena AI

Published Feb 21, 2026

Updated Feb 21, 2026

Overview

DSA transparency reports should be machine-readable, metric-defined, and reproducible. Use this template as a structure for your annual Article 15 report, expand it with Article 24 modules if you are an online platform, and add Article 42 modules if you are a VLOP or VLOSE. Replace placeholders with your actual metrics, keep a metric dictionary appendix, and publish the final report using the current Commission template rules.

Section 1

How to use this template (recommended workflow)

Treat this as a reporting workflow: data freeze -> QA -> sign-off -> publication -> archive evidence.

Include a metric dictionary so anyone can reproduce the numbers from the same data sources.

Step 1: Decide your tier modules (Article 15 only vs add Article 24 vs add Article 42).
Step 2: Populate metric dictionary (definition, source system, counting rules, validation).
Step 3: Generate report from structured datasets (avoid manual spreadsheets).
Step 4: Run QA checks and keep a QA report as part of your evidence pack.
Step 5: Export the final report in the Commission template format and archive the publication bundle, including prior versions if you republish.

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Section 2

Template mechanics required by Implementing Regulation (EU) 2024/2835

The Commission templates do more than suggest a layout. They set the reporting periods, machine-readable publication format, retention period, and correction workflow.

Build these mechanics into your reporting runbook before you start drafting sections.

Use the Annex I templates from 1 July 2025 onward for Articles 15, 24, and 42 reports.
Publish each report no later than 2 months after the reporting period ends.
Publish the completed report in ODF CSV format compliant with RFC 4180 and UTF-8 encoding.
Retain each published report, and every updated version of it, for at least 5 years.
If you update a report, clearly mark the version, explain the change, and keep all prior versions publicly available.

Section 3

Template - Executive summary (1 page)

Purpose: explain what service(s) the report covers, time period, reporting scope assumptions, and a high-level moderation and safety summary.

Keep it factual and metric-backed.

Service(s) covered, jurisdictional scope, reporting period, and contact point.
Content moderation overview: volumes, major categories, and notable changes vs prior period.
Automation and human review: what's automated, what's human-reviewed, and how accuracy is monitored.
Statement on data limitations and how you address them.

Section 4

Template - Article 15 core modules (annual report)

Use the modules below to cover Article 15 reporting elements. Only include the modules that apply to your service type (intermediary vs hosting vs platform).

For each module, include: definition, dataset, and median time calculations.

Module A: Orders from Member State authorities - volumes by illegal-content type and Member State; median times to acknowledge and act.
Module B: Hosting notices (Article 16) - volumes by alleged illegal-content type; trusted flagger volumes; action outcomes and grounds; automation usage; median time to action.
Module C: Own-initiative moderation - meaningful description of moderation; detection methods; restriction types; volumes by category.
Module D: Complaints and reversals - complaints through internal systems; bases; outcomes; median times; reversal counts.
Module E: Automated moderation - purpose, indicators of accuracy/error, and safeguards.

Section 5

Template - Article 24 modules (online platforms and search engines)

If you are an online platform, add these modules to cover Article 24(1) additions and operational duties.

Even when modules aren't published (e.g., AMAR methodology details), keep them internally for enforcement readiness.

Module F: Out-of-court dispute settlement - disputes submitted, outcomes, median completion time, implementation rate of decisions.
Module G: Suspensions under misuse protections - counts by suspension type (illegal content vs unfounded notices/complaints).
Module H: AMAR publication - AMAR in the Union (6-month average), methodology summary and QA checks (Article 24(2)).
Module I: Statement-of-reasons database submissions - process and QA controls to ensure submissions exclude personal data (Article 24(5)).

Section 6

Template - Article 42 modules (VLOPs/VLOSEs)

If you are a VLOP/VLOSE, add the modules below to meet the enhanced transparency obligations and publication/transmission requirements.

Plan for confidentiality carve-outs: publish redacted versions where allowed, but transmit full versions to authorities.

Module J: Six-month reporting cadence statement and calendar (Article 42(1)).
Module K: Moderation resources by Member State language - human resources, qualifications, training, support, and moderators with sufficient linguistic expertise. The implementing regulation uses CEFR and counts sufficient linguistic expertise from CEFR-B2 upward.
Module L: Accuracy/error indicators by language (Article 42(2)(c)).
Module M: AMAR by Member State (Article 42(3)).
Module N: Publication/transmission pack (Article 42(4)) - risk assessment report, mitigation measures, audit report, audit implementation report, and consultation information.

Section 7

Appendix - Metric dictionary (required for reproducibility)

For each metric, include enough detail to reproduce it exactly for the same period.

This appendix reduces enforcement risk and shortens audit cycles.

Metric name + DSA article mapping + definition.
Inclusions/exclusions and deduplication rules.
Source system(s), table names/fields (internal), and data owner.
Validation checks (range checks, reconciliation, anomaly detection).
Version history for metric definition changes.

Section 8

Appendix - QA checklist (run before publication)

Run QA checks every reporting cycle and archive the results with the report.

If you change counting rules, explain the change and provide comparability notes.

All required modules present for your tier and service types.
Median time calculations reproducible and well-defined.
Automation disclosures consistent with notifications sent to users/notifiers.
No prohibited personal data in public datasets/submissions.
Sign-off recorded (who approved publication and when).
Template completeness: do not omit mandatory template fields without an objective reason, because the published report can otherwise be treated as incomplete.

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